Main Job Purpose:
To ensure that activities are organised and executed in accordance with the requirements of the Guernsey regulatory framework and to support the Territory Head of Compliance in the day-to-day execution of the compliance framework of BNP Paribas Securities Services Channel Islands, ensuring activities are organised and executed in accordance with the requirements of the applicable regulatory framework, professional and ethical standards. Scope includes the domains of financial security (FS), market integrity (MI), protecting the interests of clients (PIC), professional ethics (PE) and certain regulatory topics falling within the remit of the Compliance Function as may be directed from time to time. This scope includes the related transversal responsibilities such as compliance monitoring, training, contributing to policies and procedures, maintaining registers, advising business teams and reporting.
Key Responsibilities:
Keep the Business line management as well as the Territory Head of Compliance appraised of developments in terms of the laws, regulations, rules, guidance notes, codes or standards within the Compliance area applicable to the activities, and provide guidance on the interpretation and application of the requirements. Assume the duty of assisting, providing advice and alerting senior management and employees on all matters of Compliance including those relating to Professional Ethics, Protection of the Interests of Clients, Market Integrity and Anti-Bribery and Corruption.
Analyse and advise on local Guernsey regulatory texts that relate to the above-mentioned topics, including, but not limited to, the Guernsey AML/CPT/CPF Handbook.
Ensure the business maintains an open and transparent relationship with the Guernsey Financial Services Commission. This includes co-ordinating the actions relating to any requests, visits and inspections, and ensuring timely notifications to the regulator of any reportable matters.
Implement and/or follow up recommendations made by the General Inspection, audits (internal or external) and the regulator, regarding the Compliance risks, with the Senior Management. Identify, evaluate and mitigate Compliance risks by examining all new activities, products, and exceptional transactions to ensure compliance with regulatory and BNPP requirements. Contribute to the Compliance Risk Management System (CRMS) annual questionnaires and assist with the check and challenge of the Risk and Control Self-Assessment (RCSA).
To provide support and advice on AML/CPT/CPF issues and the potential legal, regulatory, criminal and reputational risk associated with new and existing customers. Be the escalation point for complex or technical due diligence issues.
Manage the comprehensive Compliance Monitoring Plan covering the key regulatory requirements, Ensure major findings are reported to the Management Committee (as appropriate) and follow-up corrective actions, in conjunction with Permanent Controls.
Provide expertise and advice on matters within the Compliance domains. This includes advice in respect to:
The interpretation and application of policies, procedures and guidelines
Providing an opinion with respect to specific cases in accordance with policies and procedures (respecting authority as set out in the Compliance Decision Making Policy)
Client KYC files
Routing and escalating identified issues to Group Compliance when appropriate
Identify / receive / record / follow-up Regulatory breaches, Compliance-related incidents and Compliance-related complaints, advise on relevant actions to avoid recurrence and ensure that corrective measures to Compliance-related problems have been implemented in an appropriate manner and have proved their effectiveness. Ensure registers are maintained for accurate record keeping
Develop and maintain systems and controls (including policies and procedures) in line with evolving requirements within the Compliance area
Manage the tools issued by Group for detecting Money Laundering, Market Abuse and monitoring suspicious activities
Ensure that a training programme is developed and implemented with the support of HR to ensure that all staff are appropriately trained on compliance requirements within the Compliance area and maintain a strong Compliance culture with the support of the senior management
Provide reports on compliance risks and activities to the Management Committee in order to inform on regulatory developments in terms of ethics or compliance, to report on progress of compliance actions and to alert on risks of an ethical or compliance related nature. Represent the department in various Committee meetings as part of the corporate governance framework
Act in the capacity of specified roles as defined by BNP Paribas Group and/or local regulation as may be agreed with the Line Manger from time to time, for which supplemental statements of responsibilities apply: -
Money Laundering Compliance Officer
Money Laundering Reporting Officer
Compliance Officer
Act as backup/cover for the Compliance Team in Jersey and deputise for the Territory Head of Compliance on specific processes as may be advised from time to time
May act as Anti-Bribery and Corruption Officer if so appointed, in which case the relevant description of responsibilities will apply
May act as Whistleblowing Referent or Backup Referent if so appointed, in which case the relevant description of responsibilities will apply
The Compliance Manager provides reasonable assurance to the Territory Head of Compliance and to the entity management, through opinions, supervision and daily tasks, of the efficiency and consistency of the Compliance framework. He/she specifically:
Provides support and advice on Compliance issues and the potential regulatory, criminal and reputational risk associated with new and existing clients
Acts as escalation point for complex or technical Compliance issues
Manages the tools and oversight of arrangements for the processes under his/her responsibility
Reports key metrics to the relevant entity governing bodies
Supervises and coordinates the implementation and organisation of the CI Securities Services Compliance framework in terms of Compliance and the fight against bribery and corruption
Supports the Bank's efforts to build consistent and comprehensive client data framework, ensuring compliance with regulatory requirements
Identifies improvement areas and drives industrialisation and simplification initiatives across Compliance policies, processes and tools
Performs oversight on any remediation projects linked to Compliance, in close cooperation with business correspondents
Ensures consistent deployment of Group Compliance policies and procedures across CI Securities Services entities
Reports Compliance risks within his/her perimeter, specific issues and mitigation plans to the Territory Head of Compliance and the Group Compliance (e.g. results on control plans and follow up of subsequent action plans)
Makes Compliance decisions and/or delivers advice on issues reported by local and central teams, in accordance with Group escalation processes
Represents the domains under his/her responsibility as an invitee to the CI Compliance Management Committee
If assisted by team members, establishes an appropriate organisation of resources placed under his/her responsibility
Manages and acts as local business owner of certain Compliance tools as agreed with the Territory Head of Compliance
Reports suspicious activity to Group Compliance via the prescribed tool
Ensures oversight of outsourcing arrangements with Group and external service providers regarding processes under his/her responsibility
Acts as a primary point of contact for the GFSC concerning the entities for which he/she is acting as Key Person Compliance Officer
Technical Skills: Essential Requirements
Comprehensive knowledge of products and services
Extensive knowledge of Guernsey regulations
Qualifications & Industry Experience: Essential Requirements
Previous experience working as a compliance officer, MLRO and MLCO
Competencies: Essential Requirements:
Analytical Skills
Risk Management
Ability to Report
Organizational Skills
Adaptability
Integrity
Training:
Full training will be provided to the job holder as or when necessary
All compulsory training (compliance related and other) must be completed in accordance with permitted time constraints
Qualifications Supported:
Compliance related (e.g. ICA Certificate/Diploma, etc.)
Business related (e.g. CISI Diploma)
Regulatory Requirements:
Compliance Officer and MLRO roles must be approved by Guernsey regulator using online portal (i.e. Form PQ)
25 hours CPD (as per BNP Paribas Policy)
